Nacha applauds the Federal Reserve Board of Governors for issuing its proposal to extend its settlement services to support Same Day ACH enhancements with later settlement hours. The industry has spoken loudly in support of the expansion of Same Day ACH, and the public benefits it will provide for all businesses and consumers that use the ACH Network. Risks due to the extension of settlement hours can be mitigated with changes that Nacha believes the industry can gradually adopt over the next year and 10 months. These changes will better position financial institutions for ongoing improvements to the payments system.  We are glad to see the Fed take this next step to deliver on the expansion of Same Day ACH.